1. What is this privacy policy about?
SparkDynamic GmbH (hereinafter also “we”, “us”) obtains and processes personal data relating to you or also other persons (so-called “third parties”). We use the term “data” here synonymously with “personal data” or “personal data”. “Personal data” refers to data relating to specific or identifiable persons, i.e. conclusions about their identity are possible on the basis of the data itself or with corresponding additional data. In para. 3 you will find details of the data that we process within the scope of this data protection declara-tion. “Processing” means any handling of personal data, e.g. obtaining, storing, using, adapting, disclosing and deleting.
In this Privacy Policy, we describe what we do with your information when you use www.sparkdynamic.com, subdomains of this website or other websites of ours (collective-ly, the “Website”), obtain our services or products, otherwise interact with us under a con-tract, communicate with us or otherwise deal with us. Where appropriate, we will provide you with timely written notice of additional processing activities not mentioned in this Privacy Policy. In addition, we may inform you separately about the processing of your data, e.g. in consent forms, contract terms, additional privacy statements, forms and notices.
If you transmit or disclose data about other persons such as family members, work col-leagues, etc., we assume that you are authorised to do so and that this data is correct. By submitting data about third parties, you confirm this. Please also ensure that these third parties have been informed about this privacy policy.
2. Who is responsible for processing your data?
SparkDynamic GmbH, Neuhofstrasse 17, CH-8630 Rüti ZH is responsible for the data pro-cessing described in this data protection declaration, unless otherwise communicated in individual cases, e.g. in further data protection declarations, on forms or in contracts.
For each data processing operation, there is one or more bodies which are responsible for ensuring that the processing complies with the requirements of data protection law. This office is called the data controller. It is responsible, for example, for responding to re-quests for information (section 11). 11) or to ensure that personal data is secured and not used in an unauthorised manner.
Other bodies may also be jointly responsible for the data processing described in this data protection declaration if they have a say in the purpose or design. If you would like infor-mation on the individual persons responsible for a specific data processing, you are wel-come to contact us within the framework of the right to information (para. 11) to request information. SparkDynamic GmbH remains your primary contact, even if other co-responsible parties exist.
In para. 3, in para. 7 and in para. 12 you will find further information on third parties with whom we cooperate and who are responsible for their processing. If you have any ques-tions or wish to exercise your rights vis-à-vis these third parties, please contact them directly.
You can contact us for your data protection concerns and to exercise your rights in ac-cordance with para. 11 you can reach us as follows:
SparkDynamic GmbH
Neuhofstrasse 17
CH-8630 Rüti ZH
[email protected]
3. What data do we process?
We process different categories of data about you. The main categories are as follows:
• Technical data: When you use our website or other electronic offerings, we collect the IP address of your terminal device and other technical data to ensure the func-tionality and security of these offerings. This data also includes logs recording the use of our systems. In order to ensure the functionality of these offers, we may also assign an individual code to you or your end device (e.g. in the form of a cookie, cf. 12). The technical data in itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they can be linked to other data categories (and thus possibly to your person).
Technical data includes, among other things, the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser you use to access our electronic offerings. This can help us to communicate the correct formatting of the website. Based on the IP address, we know which provider you use to access our offers (and therefore also the region), but we cannot usually deduce who you are from this. This changes when you create a user account, for example, because personal data can then be linked to technical data (e.g. we can see which browser you use to access an account via our web-site). Examples of technical data also include logs that occur in our systems (e.g. the log of user logins on our website).
• Registration data: Certain offers can only be used with a user account or registra-tion, which can be done directly with us or via our external login service providers. In doing so, you must provide us with certain data and we collect data about the use of the offer or service.
• Communication data: If you are in contact with us via the contact form, by e-mail, telephone or chat, by letter or by any other means of communication, we collect the data exchanged between you and us, including your contact details and the marginal data of the communication. If we want or need to establish your identity, e.g. in the case of a request for information made by you, we collect data to iden-tify you (e.g. a copy of an identity document).
Communication data is your name and contact details, the manner and place and time of communication and usually also its content (i.e. the content of emails, let-ters, chats, etc.). This data may also include details of third parties. For identifica-tion purposes, we may also process your ID number or a password set by you.
• Master data: We use the term master data to refer to the basic data that we need, in addition to the contractual data (see below), to process our contractual and oth-er business relationships or for marketing and advertising purposes, such as name, contact details and information about, for example, your role and function, your bank account(s), your date of birth, customer history, powers of attorney, signature authorisations and consent forms. We process your master data if you are a cus-tomer or other business contact or are working for one (e.g. as a business partner contact), or because we want to contact you for our own purposes or the purposes of a contractual partner (e.g. in the context of marketing and advertising. We re-ceive master data from you yourself (e.g. when making a purchase or as part of a registration), from bodies for which you work or from third parties such as our con-tractual partners, associations and address dealers and from publicly accessible sources such as public registers or the Internet (websites, social media, etc.).
Master Data includes, for example, data such as name, address, email address, telephone number and other contact details, gender, date of birth, nationality, de-tails of associated persons, websites, social media profiles, photographs and vide-os, copies of identification documents; also details of your relationship with us (customer, supplier, visitor, service recipient etc.), details of your status with us, al-locations, classifications and distributions, details of our interactions with you (if any, a history of these with appropriate entries), reports (e.g. from the media), information about your relationship with us (e.g. from the media).), details of your status with us, allocations, classifications and distribution lists, details of our interactions with you (if applicable, a history of these with corresponding entries), reports (e.g. from the media) or official documents (e.g. excerpts from the commer-cial register, authorisations etc.) which concern you. As payment information, we collect e.g. your bank details, account number and credit card data. Consent or blocking notices are also part of the master data, as are details about third parties, e.g. contact persons, recipients of services, advertising recipients or representa-tives.
In the case of contact persons and representatives of our customers, suppliers and partners, we process as master data e.g. name and address, details of role, func-tion in the company, qualifications and, where applicable, details of superiors, em-ployees and subordinates and details of interactions with these persons.
Master data is not collected comprehensively for all contacts. Which data we col-lect in detail depends in particular on the purpose of the processing.
• Contract data: This is data that arises in connection with the conclusion or pro-cessing of a contract, e.g. information about contracts and the services to be pro-vided or provided, as well as data from the run-up to the conclusion of a contract, the information required or used for processing and information about reactions . We generally collect this data from you, from contractual partners and from third parties involved in the processing of the contract, but also from third-party sources (e.g. providers of creditworthiness data) and from publicly accessible sources.
Contract data includes information about the conclusion of the contract, about your contracts, e.g. the type and date of the conclusion of the contract, information from the application process (such as an application for our products or services) and information about the contract in question (e.g. its duration) and the processing and administration of the contracts (e.g. information relating to invoicing, customer service, assistance with technical matters and the enforcement of contractual claims). Contract data also includes information about defects, complaints and adjustments to a contract, as well as information about customer satisfaction that we may collect, for example, through surveys. Contractual data also includes financial data such as information about creditworthiness (i.e. information that allows conclusions to be drawn about the likelihood that debts will be paid), about reminders and about debt collection. We receive this data partly from you (e.g. when you make payments), but also from credit agencies and debt collection companies and from publicly accessible sources (e.g. a commercial register).
• Behavioural and preference data: Depending on our relationship with you, we try to get to know you and better tailor our products, services and offers to you. To do this, we collect and use data about your behaviour and preferences. We do this by evaluating information about your behaviour in our area, and we may also sup-plement this information with information from third parties, including publicly available sources. Based on this, we can calculate, for example, the probability that you will use certain services or behave in a certain way. Some of the data pro-cessed for this purpose is already known to us (e.g. when you use our services), or we obtain this data by recording your behaviour (e.g. how you navigate on our website). We describe how tracking works on our website in para. 12.
• Other data: We also collect data from you in other situations. In connection with official or judicial proceedings, for example, data is collected (such as files, evi-dence, etc.) that may also relate to you.
Many of the measures described in this para. 3 you disclose to us yourself (e.g. via forms, in the course of communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, subject to individual cases, e.g. within the framework of binding protection concepts (legal obligations ). If you wish to conclude con-tracts with us or claim services, you must also provide us with data, in particular master data, contract data and registration data, as part of your contractual obligation under the relevant contract. When using our website, the processing of technical data is unavoida-ble. If you wish to gain access to certain systems or buildings, you must provide us with registration data.
Insofar as this is not inadmissible, we also take data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, the media or the internet incl. social media) or receive data from authorities and other third parties (such as credit agencies, address traders, associations, contractual partners, internet analysis services etc.).
4. For what purposes do we process your data?
We process your data for the purposes we explain below. Further information for the online area can be found in para. 12 and 13. These purposes or the underlying objectives represent legitimate interests of us and, if applicable, of third parties. You will find further information on the legal basis for our processing in section 5.5.
We process your data for purposes related to communication with you, in particular to respond to enquiries and to assert your rights (para. 11) and to contact you in the event of queries. For this purpose, we use in particular communication data and master data and, in connection with offers and services used by you, also registration data. We retain this data to document our communication with you, for training purposes, for quality assur-ance and for follow-up enquiries.
We process data for the purpose of establishing, managing and processing contractual relationships.
We conclude contracts of various kinds with our customers, with suppliers or other con-tractual partners such as partners in projects or with parties in legal disputes. In this con-text, we process in particular master data, contract data and communication data and, depending on the circumstances, also registration data of the client or the persons to whom the client procures a service.
In the course of initiating business, personal data – in particular master data, contract data and communication data – are collected from potential customers or other contractual partners (e.g. in an order form or contract) or result from a communication. We also pro-cess data in connection with the conclusion of a contract to check creditworthiness and to open the customer relationship. In some cases, this information is checked for compliance with legal requirements.
As part of the processing of contractual relationships, we process data for the administra-tion of the customer relationship, for the provision and collection of contractual services (which also includes the involvement of third parties), for advice and for customer care. The enforcement of legal claims arising from contracts (debt collection, legal proceedings, etc.) is also part of the processing, as is accounting, termination of contracts and public communication.
We process data for marketing purposes and to maintain relationships, e.g. to send our customers and other contractual partners personalised advertising on products and services from us and from third parties (e.g. from advertising contractual partners). This may take the form of, for example, newsletters and other regular contacts via other channels for which we have contact information from you, but also as part of individual marketing campaigns. You can refuse such contacts at any time (see at the end of this section). 4) or refuse or withdraw your consent to be contacted for advertising purposes. With your consent, we can target our online advertising on the internet more specifically to you (see section 12). 12). Finally, we also want to enable our contractual partners to contact our customers and other contractual partners for advertising purposes (see section 7). 7) .
We continue to process your data for market research, to improve our services and operations and for product development.
We may also process your data for security and access control purposes.
We process personal data to comply with laws, directives and recommendations from authorities and internal regulations (“Compliance”).
We also process data for the purposes of our risk management and as part of prudent corporate governance, including operational organisation and corporate development.
We may process your data for other purposes, e.g. as part of our internal processes and administration.
5. On what basis do we process your data?
Insofar as we ask for your consent for certain processing (e.g. for marketing mailings, for the creation of personalised movement profiles and for advertising control and behaviour-al analysis on the website), we will inform you separately about the corresponding purposes of the processing. You can revoke consent at any time with future effect by written notification (by post) or, where not otherwise stated or agreed, by e-mail to us; our con-tact details can be found in para. 2. For the revocation of your consent for online tracking, see para. 12. Where you have a user account, revocation or contacting us may also be possible via the relevant website or other service. Once we have received notice of the withdrawal of your consent, we will no longer process your data for the purposes to which you originally consented unless we have another legal basis for doing so. The revocation of your consent will not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Where we do not ask for your consent to process your personal data, we base the processing of your personal data on the fact that the processing is necessary for the initiation or performance of a contract with you (or the entity you represent) or that we or third parties have a legitimate interest in doing so, in particular in order to fulfil the obligations set out in section 4 above. 4 and related objectives described above and to be able to take appropriate action. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognised as a legal basis by the respective applicable data protection law (e.g. in the case of the GDPR, the law in the EEA and in Switzerland). However, this also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including operations, safely and efficiently.
If we receive sensitive data (e.g. health data, information on political, religious or ideolog-ical views or biometric data for identification purposes), we may also process your data on the basis of other legal grounds, e.g. in the event of disputes due to the necessity of the processing for a possible lawsuit or the enforcement or defence of legal claims. In individ-ual cases, other legal grounds may come into play, which we will communicate to you separately where necessary.
6. What applies to profiling and automated individual decisions?
We may add certain of your personal attributes to those listed in para. 4 using your data for the purposes set out in section 4. 3) (“profiling”), if we want to determine preference data , but also to determine abuse and security risks, to carry out statistical evaluations or for operational planning purposes. For the same purposes, we can also create profiles, i.e. we can combine behavioural and preference data, but also master and contract data and technical data assigned to you, in order to better understand you as a person with your different interests and other characteristics.
7. Who do we disclose your data to?
In connection with our contracts, the website, our services and products, our legal obliga-tions or otherwise in order to protect our legitimate interests and the other interests set out in section 4. 4 we also transfer your personal data to third parties, in particular to the following categories of recipients:
• Service providers: We work with service providers in Switzerland and abroad who process data about you on our behalf or in joint responsibility with us or who re-ceive data about you from us in their own responsibility (e.g. IT providers, advertis-ing service providers, login service providers, banks, payment service providers, in-surance companies, debt collection companies or address checkers). For infor-mation on the service providers used for the website, see section 12. 12. Central IT service providers for us are Microsoft, Help Scout PBC, Cloudflare GmbH, Sucuri Website Firwall (GoDaddy Media Temple, Inc.), Usercentrics A/S . Our central payment service provider is PayPal. Our service provider for newsletters is Bee Content Design, Inc.
In order to provide our products and services efficiently and to be able to concen-trate on our core competencies, we procure services from third parties in numer-ous areas. These services include, for example, IT services, marketing services, address validators (e.g. for updating address lists in the event of relocations), and services from consulting companies, lawyers, banks, insurers and telecoms com-panies. In each case, we disclose to these service providers the data required for their services, which may also concern you. These service providers may also use such data for their own purposes. In addition, we conclude contracts with these service providers that include provisions for the protection of data, insofar as such protection does not result from the law. Our service providers may also process da-ta on how their services are used and other data that arise in the course of using their services as independent data controllers for their own legitimate interests (e.g. for statistical analysis or billing). Service providers inform about their inde-pendent data processing in their own data protection statements.
More information on how Microsoft processes data can be found here: https://privacy.microsoft.com/en-us/privacystatement .
More information on how Help Scout PBC processes data can be found here: https://www.helpscout.com/company/legal/privacy/ .
More information about how Cloudflare GmbH processes data can be found here: https://www.cloudflare.com/en-gb/privacypolicy/ .
More information on how Sucuri Website processes Firwall (GoDaddy Media Tem-ple, Inc.) can be found here: https://sucuri.net/privacy/.
More information about how Usercentrics A/S processes data can be found here: https://www.cookiebot.com/en/privacy-policy/.
More information about how PayPal processes data can be found here: https://www.paypal.com/us/legalhub/privacy-full .
More information about how Bee Content Design, Inc. processes data can be found here: https://beefree.io/privacy-policy .
• Contractual partners including customers: This initially refers to our customers and other contractual partners, because this data transfer results from these con-tracts. If you work for such a contractual partner yourself, we may also transfer da-ta about you to them in this context. The recipients also include contractual part-ners with whom we cooperate or who advertise on our behalf and to whom we therefore transfer data about you for analysis and marketing purposes (these may again be service recipients, but also e.g. sponsors and providers of online advertis-ing). We require these partners to only send you advertising or play it out based on your data if you have consented to this (for the online area, cf. para. 12).
• Authorities: We may pass on personal data to offices, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The authorities process data about you that they receive from us on their own responsibility.
• Other persons: This refers to other cases where the inclusion of third parties arises from the purposes set out in para. 4 results.
• Other recipients are, for example, delivery addressees or third-party payees speci-fied by you, other third parties also within the scope of agency relationships (e.g. if we send your data to your lawyer or your bank) or persons involved in official or legal proceedings.
All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by other third parties (e.g. authorities, banks, etc.).
We reserve the right to make these disclosures even if they concern secret data (unless we have expressly agreed with you that we will not disclose this data to certain third par-ties, unless we would be legally obliged to do so). Notwithstanding the above, your data will continue to be subject to adequate data protection even after disclosure in Switzer-land and the rest of Europe. For disclosure in other countries, the provisions of para. 8. If you do not wish certain data to be disclosed, please let us know so that we can check whether and to what extent we can accommodate you (section 2). 2).
8. Does your personal data also end up abroad?
As described in para. 7 we also disclose data to other bodies. These are not only located in Switzerland. Your data may therefore be processed in Europe and in the USA; but in excep-tional cases in any country in the world.
If a recipient is located in a country without adequate legal data protection, we contractu-ally oblige the recipient to comply with the applicable data protection (for this purpose, we use the revised standard contractual clauses of the European Commission, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de ), inso-far as it is not already subject to a legally recognised set of rules to ensure data protection and we cannot rely on an exemption provision. An exception may apply in particular in the case of legal proceedings abroad, but also in cases of overriding public interests or if the performance of a contract requires such disclosure, if you have consented or if it is a mat-ter of data that you have made generally accessible and you have not objected to its processing.
Many countries outside Switzerland or the EU and EEA currently do not have laws that guarantee an adequate level of data protection from the perspective of the DPA or the GDPR. The aforementioned contractual arrangements can partially compensate for this weaker or missing legal protection. However, contractual precautions cannot eliminate all risks (namely of state access abroad). You should be aware of these residual risks, even if the risk may be low in individual cases and we take further measures (e.g. pseudonymisa-tion or anonymisation) to minimise it.
Please also note that data exchanged via the internet is often routed via third countries. Your data can therefore end up abroad even if the sender and recipient are in the same country.
9. How long do we process your data?
We process your data for as long as our processing purposes, the statutory retention peri-ods and our legitimate interests in processing for documentation and evidence purposes require or storage is technically necessary , generally between two months and a maxi-mum of 10 years. If there are no legal or contractual obligations to the contrary, we delete or anonymise your data after the storage or processing period has expired as part of our normal processes.
Documentation and evidence purposes include our interest in documenting processes, interactions and other facts in case of legal claims, discrepancies, IT and infrastructure security purposes and evidence of good corporate governance and compliance. Retention may be technically necessary if certain data cannot be separated from other data and we therefore need to retain it with them (e.g. in the case of backups or document manage-ment systems).
10. How do we protect your data?
We take reasonable security measures to maintain the confidentiality, integrity and avail-ability of your personal data, to protect it against unauthorised or unlawful processing and to protect against the risks of loss, accidental alteration, unauthorised disclosure or access.
11. What rights do you have?
Applicable data protection law grants you the right to object to the processing of your data in certain circumstances, in particular for direct marketing, direct marketing profiling and other legitimate processing interests.
To help you control the processing of your personal data, you also have the following rights in connection with our data processing, depending on the applicable data protection law:
– The right to request information from us as to whether and which of your data we are processing;
– the right to have us correct data if it is inaccurate;
– the right to request the deletion of data;
– the right to request that we provide certain personal data in a commonly used elec-tronic format or transfer it to another controller;
– the right to withdraw consent insofar as our processing is based on your consent;
– the right to obtain, on request, further information necessary for the exercise of these rights;
If you wish to exercise any of the above rights against us, please contact us in writing, at our premises or, unless otherwise stated or agreed, by email; our contact details are set out in para. 2. In order for us to be able to exclude abuse, we must identify you (e.g. with a copy of your identity card, unless otherwise possible).
Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (e.g. to protect third parties or trade secrets). We will inform you accordingly if necessary.
If you do not agree with our handling of your rights or data protection, please let us know (para. 2). In particular, if you are in the EEA, the UK or Switzerland, you also have the right to complain to the data protection supervisory authority in your country. A list of authori-ties in the EEA can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.
12. Do we use online tracking and online advertising techniques?
We use various technologies on our website that enable us and third parties we have en-gaged to recognise you when you use our website and, in some circumstances, to track you across multiple visits. We inform you about this in this section.
In essence, this is so that we can distinguish access by you (via your system) from access by other users, so that we can ensure the functionality of the website and carry out evalu-ations and personalisations. In doing so, we do not want to infer your identity, even if we can do so insofar as we or third parties engaged by us can identify you through a combina-tion with registration data. Even without registration data, however, the technologies used are designed in such a way that you are recognised as an individual visitor each time you access the site, for example by our server (or the servers of third parties) assigning you or your browser a specific identification number (so-called “cookie”).
Cookies are individual codes (e.g. a serial number) that our server or a server of our ser-vice providers or advertising contract partners transmits to your system when you connect to our website and that your system (browser, mobile) accepts and stores until the pro-grammed expiry time. With each subsequent access, your system transmits these codes to our server or the server of the third party. In this way, you are recognised even if your identity is unknown.
Other techniques may also be used to make you more or less likely to be recognised (i.e. distinguished from other users), e.g. “fingerprinting”. Fingerprinting combines your IP address, the browser you use, the screen resolution, the language choice and other infor-mation that your system communicates to each server), resulting in a more or less unique fingerprint. In this way, cookies can be dispensed with.
Whenever you access a server (e.g. when using a website or an app or because an image is visibly or invisibly integrated in an email), your visits can therefore be “tracked” (traced). If we integrate offers from an advertising contractor or provider of an analysis tool on our website, they may track you in the same way, even if you cannot be identified in individual cases.
We use such techniques on our website and allow certain third parties to do so as well. However, depending on the purpose of these techniques, we may ask for your consent before they are used. You can program your browser to block or deceive certain cookies or alternative techniques, or to delete existing cookies. You can also enhance your browser with software that blocks tracking by certain third parties. You can find more information about this on the help pages of your browser (usually under the keyword “data protec-tion”) or on the websites of the third parties that we list below.
A distinction is made between the following cookies (techniques with comparable func-tions such as fingerprinting are included here):
– Necessary cookies: Some cookies are necessary for the website to function as such or for certain functions. For example, they ensure that you can switch between pag-es without losing information entered in a form. They also ensure that you remain logged in. These cookies are only temporary (“session cookies”). If you block them, the website may not work. Other cookies are necessary so that the server can save decisions or entries made by you beyond one session (i.e. one visit to the website) if you use this function (e.g. language selected, consent given, the function for auto-matic login etc.). These cookies have an expiry date of up to 24 months.
– Performance cookies: In order to optimise our website and corresponding offers and to better adapt them to the needs of users, we use cookies to record and ana-lyse the use of our website, possibly even beyond the session. We do this through the use of third-party analytics services. We have listed these below. Performance cookies also have an expiry date of up to 24 months. Details can be found on the websites of the third-party providers.
– Marketing cookies: We and our advertising partners have an interest in targeting advertising, i.e. displaying it only to those we want to target. We have listed our ad-vertising partners below. For this purpose, we and our advertising partners also use cookies – if you consent – which can be used to record the content accessed or con-tracts concluded. This allows us and our advertising partners to display advertise-ments that we think you may be interested in on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiry date of between a few days and 12 months depending on the situation. If you consent to the use of these cookies, you will be shown appropriate advertising. If you do not consent to these cookies, you will not see less advertising, but simply any other advertising.
In addition to marketing cookies, we use other techniques to control online advertising on other websites and thereby reduce wastage. For example, we can transmit the e-mail ad-dresses of our users, customers and other persons to whom we want to display advertising to the operators of advertising platforms. If these persons are registered there with the same e-mail address (which is determined by the advertising platforms through a com-parison), the operators show the advertising placed by us to these persons in a targeted manner. The operators do not receive personal e-mail addresses of persons who are not already known. In the case of known e-mail addresses, however, they learn that these per-sons are in contact with us and which content they have accessed.
We may also integrate further offers from third parties on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (e.g. by clicking a button), the corresponding providers can determine that you are on our website. If you have an account with the social media provider, they can assign this information to you and thus track your use of online offers. These social media providers process this data on their own responsibility.
We currently use offers from the following service providers and advertising contract partners (insofar as they use data from you or cookies set on your computer for advertising purposes):
– Google Google Ireland (based in Ireland) is the provider of the Google Analytics, Google Ads, Google reCAPTCHA, Google Authenticator and Google Tag Manager services and acts as our order processor. Google Ireland relies on Google LLC (based in the USA) as its order processor (both “Google”). Google uses performance cookies (see above) to track the behaviour of visitors to our website (duration, fre-quency of pages viewed, geographical origin of access, etc.) and compiles reports for us on the use of our website on this basis. We have configured the services in such a way that the IP addresses of visitors are shortened by Google in Europe be-fore being forwarded to the USA and thus cannot be traced. We have switched off the “Data sharing” and “Signals” settings. Although we can assume that the infor-mation we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these individuals. If you consent to the use of Google services, you explicitly agree to such processing, which also includes the transfer of personal data (in particular website and app usage data, device information and individual IDs) to the USA and other countries. Information on Google’s data protection can be found here: https://policies.google.com/privacy?hl=en-US.
13. What data do we process on our social network pages?
We may operate pages and other online presences (“fan pages”, “channels”, “profiles”, etc.) on social networks and other platforms operated by third parties and use the services described in section 3. 3 and hereinafter described data about you. We receive this data from you and the platforms when you come into contact with us via our online presence (e.g. when you communicate with us, comment on our content or visit our presence). At the same time, the platforms evaluate your use of our online presences and link this data with other data about you known to the platforms (e.g. on your behaviour and prefer-ences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g. to personalise advertising) and to control their platforms (e.g. which content they show you).
For further information on the processing of the platform operators, please refer to the data protection notices of the platforms. There you will also find out in which countries they process your data, which rights of access, deletion and other data subjects you have and how you can exercise these or obtain further information. We currently use the follo-wing platforms:
– LinkedIn: When visiting our LinkedIn page, LinkedIn, LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland as the responsible party, col-lects personal data of the user, for example through the use of cookies. Such data collection by LinkedIn may also occur for visitors to the LinkedIn site or this channel who are not logged in or registered with LinkedIn. Information on data collection and further processing by LinkedIn can be found in LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy. We cannot trace which user data LinkedIn collects. Nor do we have full access to the data collected or your profile data. We can only see the public information of your profile. You decide what this is specifically in your LinkedIn settings. We would like to point out that we are not re-sponsible for the data processing carried out by LinkedIn and cannot influence this.
– Vimeo: We also use services of the company Vimeo LLC on our website. The video portal is operated by Vimeo LLC, 330 West 34th Street, 5th Floor New York, New York 10001, USA. With the help of a plug-in, we can show you video material direct-ly on our website. Certain data may be transferred from you to Vimeo in the pro-cess. For information on data collection and further processing by Vimeo, please see Vimeo’s privacy policy at https://vimeo.com/privacy. We cannot trace which user data Vimeo collects. We would like to point out that we are not responsible for the data processing carried out by Vimeo and cannot influence this.
14. Can this privacy policy be changed?
This Privacy Policy does not form part of any contract with you. We may amend this priva-cy policy at any time. The version published on this website is the current version.
Last updated: 31.10.2023
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